Policy regarding the processing of personal data

1. General provisions

This personal data processing policy is drawn up in accordance with the requirements of the Federal Law of July 27, 2006. №152-FZ «On Personal Data» (hereinafter referred to as the Law on Personal Data) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by the individual entrepreneur "Zavgorodnyaya A.A" (hereinafter referred to as – Operator).

1.1. The operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of man and citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter –the Policy) applies to all information that the Operator may obtain about visitors to the website https://zvgrgallery.com.

2. Basic concepts used in the Policy

 2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website – a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://zvgrgallery.com.
2.4. Personal data information system — a set of personal data contained in databases, and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine without the use of additional information whether personal data belongs to a specific User or other subject of personal data.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – state body, municipal body, legal entity or individual, independently or jointly with other persons, organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable Website User https://zvgrgallery.com.
2.9. Personal data permitted by the subject of personal data for distribution - personal data, access of an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data, permitted for distribution).
2.10. User – any visitor to the website https://zvgrgallery.com.
2.11. Providing personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including publishing personal data in the media, posting on information and telecommunication networks or providing access to personal data in some other way.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data is destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and (or) material carriers of personal data are destroyed.

3. Basic rights and obligations of the Operator

 3.1. The operator has the right to:
– receive reliable information and/or documents containing personal data from the subject of personal data;
–if the subject of personal data withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data, if there are grounds specified in the Law on Personal Data;
– independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The operator shall:
– provide the subject of personal data, at his request, with information regarding the processing of his personal data;
– organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
– respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– report to the authorized body for the protection of the rights of personal data subjects, at the request of this body, the necessary information within 30 days from the date of receipt of such a request;
– publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
– take legal, organizational and technical measures to protect personal data from unlawful or accidental access to it, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
–to stop the transfer (distribution, provision, access) of personal data, to stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;
– perform other duties as provided for in the Personal Data Act.

4. Basic rights and obligations of personal data subjects

 4.1. Subjects of personal data have the right to: – receive information regarding the processing of his personal data, except in cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data; – require the operator to clarify his personal data, block them or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processingand also take measures provided for by law to protect your rights; – put forward a condition of prior consent when processing personal data in order to promote goods, works and services on the market; – to revoke consent to the processing of personal data; – appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inactions of the Operator when processing his personal data; – to exercise other rights provided for by the legislation of the Russian Federation.– appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inactions of the Operator when processing his personal data; – to exercise other rights provided for by the legislation of the Russian Federation.– appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inactions of the Operator when processing his personal data; – to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to: – provide the Operator with reliable data about themselves; – inform the Operator about clarification (updating, changing) of your personal data.
4.3. Persons who provided the Operator with false information about themselves, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User

5.1. Last name, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. Year, month, date and place of birth.
5.5. The site also collects and processes anonymized data about visitors (including cookies«) using Internet statistics services (Yandex Metrica and Google Analytics and others).
5.6. The above data is further united in the text of the Policy by the general concept of Personal Data.
5.7. The Operator does not process special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, or intimate life. 5.8. The processing of personal data authorized for distribution from among the special categories of personal data specified in Part 1 of Art. 10 of the Law on Personal Data is permitted if the prohibitions and conditions provided for in Art. 10.1 of the Law on Personal Data are observed.
5.9. The User's consent to the processing of personal data permitted for distribution is formalized separately from other consents to the processing of his personal data. In this case, the conditions provided for, in particular, Art. 10.1 of the Law on Personal Data. Requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.9.1 The User provides consent to the processing of personal data permitted for distribution to the Operator directly.
5.9.2 The Operator is obliged, no later than three working days from the date of receipt of the specified consent of the User, to publish information about the conditions of processing, the existence of prohibitions and conditions for the processing of personal data permitted for distribution by an unlimited number of persons.
5.9.3 The transfer (distribution, provision, access) of personal data authorized by the subject of personal data for distribution must be terminated at any time at the request of the subject of personal data. This requirement must include the last name, first name, patronymic (if any), contact information (telephone number, email address or postal address) of the subject of personal data, as well as a list of personal data the processing of which is subject to termination. The personal data specified in this requirement can only be processed by the Operator to whom it is sent.
5.9.4 Consent to the processing of personal data permitted for distribution ceases to be valid from the moment the Operator receives the requirement specified in paragraph. 5.9.3 of this Policy regarding the processing of personal data.

6. Principles for processing personal data

 6.1. The processing of personal data is carried out on a legal and fair basis.
6.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
6.4. Only personal data that meets the purposes of their processing are subject to processing.
6.5. The content and scope of the personal data processed correspond to the stated purposes of the processing. Redundancy of the personal data processed in relation to the stated purposes of their processing is not allowed. 6.6. When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data are ensured. The operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
6.7. Storage of personal data is carried out in a form that allows you to identify the subject of personal data, no longer than required by the purpose of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The personal data processed is destroyed or depersonalized upon achieving the purposes of processing or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.

7. Purposes of processing personal data
7.1. Purpose of processing the User's personal data:
– informing the User by sending emails;
– conclusion, execution and termination of civil contracts;
–providing access to the User to the services, information and/or materials contained on the website https://zvgrgallery.com.
7.2. The Operator also has the right to send notifications to the User about new products and services, special offers and various events. The User can always refuse to receive information messages by sending an email to the Operator alina.zvgr@gmail.com marked «Refusal to notify new products and services and special offers».
7.3. Anonymized User data collected using Internet statistics services serves to collect information about Users’ actions on the site, improve the quality of the site and its content.

8. Legal basis for processing personal data
8.1. The legal grounds for the processing of personal data by the Operator are
– contracts concluded between the operator and the subject of personal data;
– federal laws and other regulations in the field of personal data protection;
– consent of Users to the processing of their personal data, to the processing of personal data permitted for distribution.
8.2. The Operator processes the User’s personal data only if it is filled out and/or sent by the User independently through special forms located on the site alina.zvgr@gmail.com or sent to the Operator via email. By filling out the appropriate forms and/or sending his personal data to the Operator, the User expresses his agreement with this Policy.
8.3. The Operator processes anonymized data about the User if this is allowed in the User's browser settings (saving files «cookies» and using JavaScript technology are enabled.
8.4. The subject of personal data independently decides on the provision of his personal data and gives consent freely, by his will and in his interest.

9. Conditions for processing personal data
9.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
9.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or law, to carry out the functions, powers and responsibilities assigned by the legislation of the Russian Federation to the operator.
9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is necessary for the execution of a contract to which the subject of personal data is a party or a beneficiary or guarantor, as well as for concluding a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
9.6. Personal data is processed, access to which is provided by the subject of personal data to an unlimited number of persons or at his request (hereinafter referred to as publicly available personal data).
9.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

10. The procedure for the collection, storage, transfer and other types of processing of personal data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

10.1. The operator ensures the safety of personal data and takes all possible measures to prevent access to personal data of unauthorized persons.
10.2. The User’s personal data will never, under any circumstances, be transferred to third parties, with the exception of cases related to the implementation of current legislation or if the subject of personal data gives consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.
10.3. If inaccuracies are identified in personal data, the User can update them independently by sending the Operator a notification to the Operator’s email address alina.zvgr@gmail.com marked «Updating personal data».
10.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for in the contract or current legislation. The User may at any time withdraw his consent to the processing of personal data by sending a notification to the Operator via email to the Operator’s email addressalina.zvgr@gmail.com marked «Withdrawal of consent to the processing of personal data».
10.5. All information collected by third-party services, including payment systems, communications and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to independently familiarize himself with these documents in a timely manner. The operator is not responsible for the actions of third parties, including service providers specified in this paragraph.
10.6. Prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions for processing (except for obtaining access) of personal data permitted for distribution do not apply in cases of processing personal data in state, public and other public interests determined by legislation RF.
10.7. The operator ensures the confidentiality of personal data when processing personal data.
10.8. The operator stores personal data in a form that allows identifying the subject of personal data no longer than required by the purpose of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject is a party, beneficiary or guarantor.
10.9. A condition for termination of processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data or the withdrawal of consent by the subject of personal data, as well as the identification of unlawful processing of personal data.

11. List of actions performed by the Operator with the received personal data
11.1. The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
11.2. The operator carries out automated processing of personal data with or without receiving and/or transmitting received information over information and telecommunication networks.

12. Cross-border transfer of personal data
12.1. Before starting the cross-border transfer of personal data, the operator is obliged to make sure that the foreign state to whose territory the transfer of personal data is intended ensures reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can only be carried out if the subject of personal data agrees in writing to the cross-border transfer of his personal data and/or the execution of a contract to which the subject of personal data is a party.

13. Confidentiality of personal data The operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the subject of personal data, unless otherwise provided by federal law.

14. Final provisions
14.1. The User can obtain any clarification on issues of interest regarding the processing of his personal data by contacting the Operator via email alina.zvgr@gmail.com.
14.2. This document will reflect any changes in the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at: https://zvgrgallery.com/policy/.